Understanding Ballast Water Management Dispensation Letters

Imagine this scenario: your vessel encounters Challenging Water Quality (CWQ) conditions that make it impossible to use the Ballast Water Treatment System (BWTS). Perhaps the water is heavily contaminated, causing filtration issues or low salinity, rendering the electro-chlorination system ineffective. In such a situation, you might need to bypass the BWTS entirely.

But this raises a critical question: Do you need a Dispensation Letter before bypassing the system?

For years, the Ballast Water Management Convention (BWM) lacked specific rules on this issue, leaving mariners to rely on simple logic. However, things changed with the adoption of Resolution MEPC.387(81) on March 22, 2024, which provides Interim Guidance on the Application of the BWM Convention to Ships Operating in Challenging Water Quality Conditions.

Let’s dive into what this resolution says about bypass scenarios and how they impact your operations.

Reactive vs. Pre-Emptive Bypass: What’s the Difference?

The resolution introduces two distinct types of bypasses: Reactive and Pre-Emptive. Each type addresses a specific operational challenge.

Reactive Bypass

When is it used?

A reactive bypass occurs when unforeseen CWQ issues arise while operating or upon arrival at the port.

Key Steps:

• Verify the issue is due to CWQ (e.g., dirty ballast water or low salinity) and not a technical malfunction.
• Record the situation and corrective actions in the…

CONTINUE READING THE ARTICLE FROM MarineInsight HERE